Air Quality Division
State Registration Number / RENEWABLE OPERATING PERMIT / ROP Number
P0426 / STAFF REPORT / MI-ROP-P0426-2014
ADRIAN ENERGY ASSOCIATES, LLC
SRN: P0426
Located at
1900 North Ogden Highway, Adrian, Lenawee, Michigan 49221
Permit Number: MI-ROP-P0426-2014
Staff Report Date: April 21, 2014
This Staff Report is published in accordance with Sections 5506 and 5511 of Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act 451). Specifically, Rule 214(1) requires that the Michigan Department of Environmental Quality (MDEQ), Air Quality Division (AQD), prepare a report that sets forth the factual basis for the terms and conditions of the Renewable Operating Permit (ROP).
TABLE OF CONTENTS
APRIL 21, 2014 STAFF REPORT 3
MAY 22, 2014 STAFF REPORT ADDENDUM 9
Michigan Department of Environmental QualityAir Quality Division
State Registration Number / RENEWABLE OPERATING PERMIT / ROP Number
P0426 /
APRIL 21, 2014 STAFF REPORT
/ MI-ROP-P0426-2014Purpose
Major stationary sources of air pollutants, and some non-major sources, are required to obtain and operate in compliance with a ROP pursuant to Title V of the federal Clean Air Act of 1990 and Michigan’s Administrative Rules for air pollution control pursuant to Section 5506(1) of Act 451. Sources subject to the ROP program are defined by criteria in Rule 211(1). The ROP is intended to simplify and clarify a stationary source’s applicable requirements and compliance with them by consolidating all state and federal air quality requirements into one document.
This report, as required by Rule 214(1), sets forth the applicable requirements and factual basis for the draft permit terms and conditions including citations of the underlying applicable requirements, an explanation of any equivalent requirements included in the draft permit pursuant to Rule 212(5), and any determination made pursuant to Rule 213(6)(a)(ii) regarding requirements that are not applicable to the stationary source.
General Information
Stationary Source Mailing Address: / Adrian Energy Associates, LLC1900 North Ogden Highway
Adrian, Michigan 49221
Source Registration Number (SRN): / P0426
North American Industry Classification System (NAICS) Code: / 221119
Number of Stationary Source Sections: / 1
Is Application for a Renewal or Initial Issuance? / Initial IssuanceRenewal
Application Number: / 201300096
Responsible Official: / Dennis Plaster, Vice President of Operations
585-948-8580
AQD Contact: / Diane Kavanaugh Vetort, Senior Environmental Quality Analyst
517-780-7864
Date Permit Application Received: / June 7, 2013
Date Application Was Administratively Complete: / June 19, 2013
Is Application Shield In Effect? / YesNo
Date Public Comment Begins: / April 21, 2014
Deadline for Public Comment: / May 21, 2014
Source Description
Adrian Energy Associates, LLC (Adrian Energy) owns and operates three Caterpillar G3516 reciprocating internal combustion engines (RICE) and a landfill gas (LFG) treatment system. Adrian Energy receives collected LFG from Adrian Landfill Inc., located at the same site and owned and operated by Republic Services Inc.. The LFG is sent to the LFG treatment system; it is filtered, dewatered, compressed and cooled in the system. The RICE use the conditioned LFG as fuel for the generation of electricity for the power grid. There are no atmospheric vents or emissions from the LFG treatment system; any gas not conditioned in the system is directed to and burned in the Open Flare owned and operated by Adrian Landfill. The LFG treatment system is subject to 40 CFR Part 60, Subpart A and WWW because the equipment provides the air pollution control of the Non-Methane Organic Compound emissions from the LFG generated by Adrian Landfill a New Source Performance Standard (NSPS) Municipal Solid Waste Landfill, affected source.
Although Adrian Energy is a separately owned and operated company located on the same location as Adrian Landfill, together they are considered one stationary source. Adrian Landfill has a separate ROP incorporating the active Type II sanitary landfill (Municipal Solid Waste Landfill). The two companies have a contractual agreement in which Adrian Landfill sells LFG to Adrian Energy. The contractual and spatial relationship of the two facilities establishes Adrian Landfill Inc., as the controlling entity of the partnership. On March 21, 2013, an agreement was made between Michigan’s Air Quality Division, the management of Adrian Landfill, Inc. and Adrian Energy, which allowed the two entities to have separate Renewable Operating Permits. However, pursuant to Michigan’s Air Pollution Control Rules, specifically Rule 336.119(r), together these entities comprise one single stationary source. A new State Registration Number (SRN) was issued to Adrian Energy Associates. The SRN for Adrian Landfill, Inc. is N2369, and the SRN for Adrian Energy Associates is P0426.
After the LFG is combusted by the engines and the flare, the following pollutants may be emitted into the ambient air: Non-methane organic compounds (NMOC), volatile organic compounds (VOC), nitrogen oxides (NOx), sulfur dioxide (SO2), particulate matter (PM), Hydrogen Chloride (HCl) and Formaldehyde (HCHO).
The following table lists stationary source emission information (combined with Adrian Landfill) as reported to the Michigan Air Emissions Reporting System in the 2012 submittal.
TOTAL STATIONARY SOURCE EMISSIONS
Pollutant / Tons per Year /Carbon Monoxide (CO) / 58
Nitrogen Oxides (NOx) / 31
Particulate Matter (PM) / 10
Sulfur Dioxide (SO2) / 3
Volatile Organic Compounds (VOCs) / 3
Non-methane organic compounds (NMOCs) / 12
Individual Hazardous Air Pollutants (HAPs) **
Total Hazardous Air Pollutants (HAPs) / NA
**As listed pursuant to Section 112(b) of the federal Clean Air Act.
In addition to the pollutants listed above that have been reported in MAERS, the potential to emit of Greenhouse Gases in tons per year of CO2e is less than 100,000. CO2e is a calculation of the combined global warming potentials of six Greenhouse Gases (carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride).
As part of the Adrian Energy renewal application and an additional information request (response letter dated January 24, 2014) Derenzo and Associates, consultant for Adrian Energy, included the following Source-Wide Potential to Emit (PTE) for Hazardous Air Pollutants (HAPs). Prior estimates were based on available information from equipment manufacturers and default emission factors published by USEPA (AP-42 Section 2.4 for municipal solid waste landfills). Recently RICE manufacturers and operators have identified formaldehyde as a potential emission from LFG combustion. The PTE calculations are based on an updated estimated formaldehyde emission factor provided by Caterpillar Inc., for the three CAT G3516 Gas Engines operated by Adrian Energy.
Hydrogen Chloride (HCl): / 1.7 TPY / AP-42Formaldehyde (HCHO): / 9.9 TPY / Caterpillar EF 0.26 grams per brake horsepower-hour (g/bhp-hr) plus 15%
Other LFG: / 0.96 TPY / AP-42
Total HAPs: / 12.6 TPY
See Parts C and D in the draft ROP for summary tables of all processes at the stationary source that are subject to process-specific emission limits or standards.
Regulatory Analysis
The following is a general description and history of the source. Any determinations of regulatory non-applicability for this source are explained below in the Non-Applicable Requirement part of the Staff Report and identified in Part E of the ROP.
The stationary source is located in Lenawee County, which is currently designated by the U.S. Environmental Protection Agency (USEPA) as attainment/unclassified for all criteria pollutants.
The stationary source is subject to Title 40 Code of Federal Regulations, Part 70; because the associated landfill is subject to the New Source Performance Standard (NSPS) for Municipal Solid Waste Landfills, which was promulgated in Title 40 of the Code of Federal Regulations, Part 60, Subparts A and WWW, and the Maximum Achievable Control Technology (MACT) Standard for Municipal Solid Waste Landfills, which was promulgated in Title 40 of the Code of Federal Regulations, Part 63, Subparts A and AAAA.
The stationary source is considered to be a minor source of HAP emissions because the potential to emit of any single HAP regulated by the federal Clean Air Act, Section 112, is less than 10 tons per year and the potential to emit of all HAPs combined are less than 25 tons per year.
The stationary source is considered a “synthetic minor” source in regards to Prevention of Significant Deterioration of Title 40 of the Code of Federal Regulations, Part 52.21, regulations since the stationary source has accepted legally enforceable permit conditions limiting the potential to emit of CO to less than 250 tons per year.
At this time, there are no GHG applicable requirements to include in the ROP. The mandatory Greenhouse Gas Reporting Rule under 40 CFR 98 is not an ROP applicable requirement and is not included in the ROP.
EUTREATMENTSYS at the stationary source is subject to the Standards of Performance for Municipal Solid Waste Landfills promulgated in 40 CFR, Part 60, Subparts A and WWW.
FGENGINES at the stationary source are subject to the National Emission Standard for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (Landfill gas spark ignition-ICE) promulgated in 40 CFR, Part 63, Subparts A and ZZZZ (Area Source RICE MACT). The ROP contains special conditions provided by Adrian Energy for applicable requirements from 40 CFR, Part 63, Subparts A and ZZZZ. The AQD is not delegated the regulatory authority for this Area Source MACT; therefore, the special conditions for the RICE Area Source MACT contained in FGRICEMACT were not reviewed by the AQD.
On February 10, 2009, the DEQ-AQD approved and issued ROP No. MI-ROP-N2369-2009 to then Adrian Landfill, Inc. & Adrian Energy Associates pursuant to R336.1214. A Minor Modification application pursuant to R 336.1216(2) was submitted by Adrian Energy on August 26, 2009, to incorporate record keeping procedure changes (some from daily to weekly) to conditions of Permit to Install No. 145-09 for FGENGINES. The ROP revision MI-ROP-N2369-2009a was issued April 13, 2012.
On March 12, 2013, Adrian Energy submitted a EUICENGINE#3 replacement notification. The engine Serial No. 4EK00283, Manufacturer build date August 18, 1994, horsepower rating 1,138 was replaced with a like engine Serial No. 4EK00962, Manufacturer build date, June 6, 1996, horsepower rating 1,138. In the RO application the following engine inventory was provided indicating that EUICENGINE#1 was also previously replaced:
Engine No. / Model No. / Install Date / Engine Replacement / Serial No. / Manufacture Build DateEUICENGINE#1 / CAT G3516 / 12/31/1994 / 05/06/2011* / 4EK00580 / 08/23/1995
EUICENGINE#2 / CAT G3516 / 12/31/1994 / NA / 4EK00282 / 08/18/1994
EUICENGINE#3 / CAT G3516 / 12/31/1994 / 02/07/2013* / 4EK00962 / 06/06/1996
*EUICENGINE#1 Like-kind replacement. (Original Serial No. 4EK00276) Engine serial number in table is the current engine serial number.
*EUICENGINE#3 Like-kind replacement. (Original Serial No. 4EK00283) Engine serial number in table is the current engine serial number.
NA not applicable
The current ROP contains EUTREATMENTSYS, FGENGINES, and a new flexible group has been added FGRICEMACT to incorporate the new federal applicable requirement of 40 CFR 63, Subparts A and ZZZZ to FGENGINES.
EUTREATMENTSYS contains the federal applicable requirements of NSPS Subpart WWW for operating and maintaining a Treatment System. The ROP requires, and references in the Appendix 9, the company’s Start-up, Shut down and Malfunction Plan and Preventative Maintenance Plan for the system.
FGENGINES contains EUICENGINE#1, EUICENGINE#2, and EUICENGINE#3. FGENGINES contains CO, and NOx emission limitations with applicable requirements from the initial Permit to Install No. 145-09 of R 336.1225 (Rule 225), R336.1901 (Rule 901), and 40 CFR 52.21(d), and VOC emission limit with applicable requirements of Rule 225, Rule 901 and R 336.1702(a) (Rule 702). FGENGINES contains conditions requiring operating parameter monitoring, recording keeping, and calculations necessary to determine emissions.
During Technical review the original Permit to Install application was reviewed for inclusion of formaldehyde and it was found to have not been included in the list of toxic air contaminants at that time. The current ROP includes performance testing requirements to determine emissions of both VOC and formaldehyde.
FGENGINES contains performance testing requirements for each of the three EUICENGINES because only EUICENGINE#2 has been previously tested, in 2007. Furthermore, current industry information and new source permit evaluations indicate Formaldehyde HAP is present in LFG engine emissions. The HAP PTE provided by Adrian Energy during technical review indicates emissions are very close to the individual HAP major source threshold limit. Performance testing will verify HAP stationary source status and establish the associated ongoing compliance operating and monitoring parameters. The underlying applicable requirement is Rule 213 (3).
The monitoring conditions contained in the ROP are necessary to demonstrate compliance with all applicable requirements and are consistent with the "Procedure for Evaluating Periodic Monitoring Submittals."
No emission units are subject to the federal Compliance Assurance Monitoring rule under 40 CFR, Part 64, because all emission units at the stationary source either do not have a control device or those with a control device do not have potential pre-control emissions over the major source thresholds.
Please refer to Parts B, C and D in the draft ROP for detailed regulatory citations for the stationary source. Part A contains regulatory citations for general conditions.
Source-wide Permit to Install (PTI)
Rule 214a requires the issuance of a Source-wide PTI within the ROP for conditions established pursuant to Rule 201. All terms and conditions that were initially established in a PTI are identified with a footnote designation in the integrated ROP/PTI document.
The following table lists all individual PTIs that were incorporated into previous ROPs. PTIs issued after the effective date of ROP No. MI-ROP-N2369-2009 are identified in Appendix 6 of the ROP.
PTI Number /10-96 / 105-91
Streamlined/Subsumed Requirements
The following table lists explanations of any streamlined/subsumed requirements included in the ROP pursuant to Rules 213(2) and 213(6). All subsumed requirements are enforceable under the streamlined requirement that subsumes them.
This permit does not include any streamlined/subsumed requirements pursuant to Rules 213(2) and 213(6).
Non-applicable Requirements
Part E of the draft ROP lists requirements that are not applicable to this source as determined by the AQD, if any were proposed in the application. These determinations are incorporated into the permit shield provision set forth in Part A (General Conditions 26 through 29) of the draft ROP pursuant to